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21/09/2026
13/09/2026
25/08/2026
19/08/2026

The (SC) has ruled that a sales agentโ€™s promise to issue a Contract to Sell after payment of reservation fee is not an โ€œadvertisementโ€ under Presidential Decree No. (PD) 957, or the ๐˜š๐˜ถ๐˜ฃ๐˜ฅ๐˜ช๐˜ท๐˜ช๐˜ด๐˜ช๐˜ฐ๐˜ฏ ๐˜ข๐˜ฏ๐˜ฅ ๐˜Š๐˜ฐ๐˜ฏ๐˜ฅ๐˜ฐ๐˜ฎ๐˜ช๐˜ฏ๐˜ช๐˜ถ๐˜ฎ ๐˜‰๐˜ถ๐˜บ๐˜ฆ๐˜ณ๐˜ดโ€™ ๐˜—๐˜ณ๐˜ฐ๐˜ต๐˜ฆ๐˜ค๐˜ต๐˜ช๐˜ท๐˜ฆ ๐˜‹๐˜ฆ๐˜ค๐˜ณ๐˜ฆ๐˜ฆ, that would form part of developerโ€™s warranties. However, the developer may still be required to refund a buyer if it fails to honor that promise.

In a Decision written by Associate Justice Maria Filomena D. Singh, the SCโ€™s Third Division ordered Empire East Land Holdings, Inc. (Empire East) to refund the payments made by John Edrem Bautista (Bautista) after it failed to issue the promised Contract to Sell.

Bautista paid Empire East for a residential unit PHP 130,000, consisting of a PHP 20,000 reservation fee and PHP 110,000 in additional payments. He claimed he made the payments because Empire Eastโ€™s sales agent promised to issue a Contract to Sell once he paid the reservation fee. When more than a year passed without the contract being issued, Bautista stopped making payments and demanded a refund.

The SC, agreeing with both the Human Settlements Adjudication Commission (HSAC) and the Court of Appeals which ruled in Bautistaโ€™s favor, held that Bautista was entitled to a refund but clarified that the sales agentโ€™s promise did not fall under Section 19 of PD 957.

The SC clarified that Section 19, which mandates truthful and non-misleading advertisements and sales materials, applies only to materials intended for the general public, such as those in those in newspapers, radio, TV, or similar mass communication channels. It does not cover promises made by a sales agent to individual buyers.

The SC emphasized that buyers remain protected, as developers may still be held liable under their contractual obligations and other applicable laws.

The SC ordered Empire East to refund Bautista the PHP 130,000 with interest of 6% per annum reckoned from the filing of the complaint in 2012, as well as to pay PHP 260,000 in exemplary damages, which courts award to discourage wrongful conduct and warn against similar actions.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=171359.

Read the full text of the Decision at https://sc.judiciary.gov.ph/wp-content/uploads/2026/05/272556-1.pdf.

Copying of this content is subject to the SC PIOโ€™s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attributionon-policy.

05/08/2026
25/07/2026

๐—•๐—œ๐—ฅ ๐—œ๐—ฆ๐—ฆ๐—จ๐—˜๐—ฆ ๐—–๐—Ÿ๐—”๐—ฅ๐—œ๐—™๐—œ๐—–๐—”๐—ง๐—œ๐—ข๐—ก๐—ฆ ๐—ข๐—ก ๐—ข๐—ก๐—˜-๐—ง๐—œ๐— ๐—˜ ๐—”๐—•๐—”๐—ง๐—˜๐— ๐—˜๐—ก๐—ง ๐—ฃ๐—ฅ๐—ข๐—š๐—ฅ๐—”๐—  ๐—™๐—ข๐—ฅ ๐— ๐—œ๐—–๐—ฅ๐—ข ๐—ง๐—”๐—ซ๐—ฃ๐—”๐—ฌ๐—˜๐—ฅ๐—ฆ

The Bureau of Internal Revenue (BIR) has issued Revenue Memorandum Circular (RMC) No. 84-2026, providing clarifications on the implementation of Revenue Regulations (RR) No. 4-2026, which prescribes the guidelines and procedures for the availment of the One-Time Abatement of Taxes and/or Penalties for Micro Taxpayers.

The Circular adopts a Question-and-Answer format to address common concerns regarding taxpayer qualification, documentary requirements, filing procedures, payment of the one-time abatement fee, covered tax liabilities and penalties, application timelines, and other implementation issues. It also provides illustrative examples to guide taxpayers in determining their eligibility under the program.

Among the clarifications, the Circular explains that taxpayers may verify their classification as a Micro Taxpayer through the BIR Online Registration and Update System (ORUS) or by coordinating with their respective Revenue District Offices. It likewise clarifies that only qualified cases existing as of December 31, 2025, and meeting the requirements under RR No. 4-2026, are covered by the program.

The Circular further explains the treatment of pending compromise and abatement applications, one-time transactions, open case penalties, multiple taxable years, partial payments, and other situations that may arise in the implementation of the One-Time Abatement Program. It also outlines the grounds for denial of applications and clarifies the significance of the Certificate of Availment issued to qualified applicants.

Taxpayers are encouraged to read RMC No. 84-2026 to better understand the requirements and procedures for availing of the One-Time Abatement Program for Micro Taxpayers.

Read the full Revenue Memorandum Circular here: https://bir-cdn.bir.gov.ph/BIR/pdf/RMC%20No.%2084-2026_Redacted.pdf?fbclid=IwY2xjawTQWyJwZG9mAWV4dG4DYWVtAjEwAGJyaWQRMVFkSjZPM0ZhdG5JRmZUQUNzcnRjBmFwcF9pZBAyMjIwMzkxNzg4MjAwODkyAAEe17gKGXp2IsePoanRJjj4yAOiYqz_dCFe3EOTuNT2u040a2z8BntvDAwt0hA_aem_GATcFj98ZTulvKNB4xCrBQ

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2F Amall Bldg Rizal Street
Ormoc City
6541

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Tuesday 9am - 5pm
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